There is a great deal of pressure to
rebuild Public Housing north of
Broadway in high-poverty neighborhoods for political and financial
reasons that are at odds with the best interests of the poor people
that these units are meant to serve. Building developments
there that are composed of 100% Public Housing units might be too
obvious of a violation of the
Fair Housing Act (FHA) for some involved, so
the City is being ordered
to use mixed-income development, under the pretense that it will void,
or at least hide, the fair-housing violations created by building in
these high-poverty locations. The extra unneeded units
required to build
mixed-income also has the added benefit for the Poverty Industry of
raising the cost.

The two
fundamental mandates of the FHA are that Public
Housing development
must de-concentrate poverty and race/ethnicity. The more
recent and
sophisticated rulings, like Thompson v HUD, go a step further and seek
to define census tracts (the official definition of neighborhoods) by
the amount of opportunity that they provide for their residents. Some
fair-housing experts have even devised objective scoring and ranking
systems to quantify and compare census tracts.

These experts see opportunity
arising from the resources available and
people residing in a neighborhood, not just the block
where they live,
or their apartment building or condo complex; areas that are just too
small to be meaningful. Opportunity
has been demonstrated to be the
highest in low-poverty census tracts; those with less than 10% poverty.
This is why Public Housing should be built in census tracts with less
than 10% poverty.

HUD must believe that building
mixed-income developments inside existing high-poverty census
tracts will transform the neighborhood from high poverty to
low
poverty;
because that is what they must do to meet the latest requirements of
the FHA. If a new development
is unable to transform the neighborhood,
then it should be built in an existing low-poverty census tract.

For example, if a 10-unit luxury apartment complex was built
next to Sandpiper Cove (in the census tract with the highest
poverty in the
entire County), and it contained nine millionaires and one Public
Housing
family, would the apartment
building itself be enough to provide
sufficient opportunity to the Public Housing family?
Common sense would
dictate that they need
resources far beyond just what is contained in
their own building, no matter how prosperous their
neighbors may be.

Compare this example to what the City is currently being ordered to
build: a
122-unit mixed-income development on the Cedar Terrace footprint;
a few
blocks away from Sandpiper Cove, which is also in the census
tract with the highest poverty in the entire County. They must build 49
PH
units, 12 LITC/PBV units,
12 LITC units, and 49 MR units. If the development works as planned 49
PH + 12 LITC/PBV = 61 units will house residents below poverty, and 61
units will house residents above poverty.

Before this is built, the
poverty level in this census tract (CT 7246) is 61%.
After it is built, if it works perfectly, it
will only lower the
poverty level of the census tract to 59%, clearly
demonstrating that
mixed-income development
does NOT even come close to transforming this
neighborhood into an acceptable low-poverty census tract. If
the
manager fails to fill the other 61 units with people above the poverty
level, and the entire development ends up filled with people below
poverty; it will INCREASE the
poverty rate of the neighborhood from 61%
to 67%. (see Appendix below for details
and calculations)

It
is completely dishonest to claim that mixed-income
development at Cedar Terrace, or in other high-poverty census tracts,
can change the demographics of the census tract enough to make it an
acceptable location for Public Housing. Nothing could be
further from
the truth!

The calculations clearly show that building
mixed-income in
high-poverty census tracts violates the FHA just as clearly as building
100% PH
does. There is actually very little difference.

But that's not all!

The City is also currently being ordered to build: a 160-unit mixed-income
development on the Magnolia footprint. They must build 64
PH
units, 16
LITC/PBV units, 16 LITC units, and 64 MR units. If the development
works as planned 64 PH + 16 LITC/PBV = 80 units will house residents
below poverty, and 80 units will house residents above poverty.

Before this is built, the
poverty level in this census tract (CT 7243) is 26%.
After it is built, if it works perfectly, it
will actually RAISE the
poverty level of the census tract to 28% clearly
demonstrating that
mixed-income development
cannot transform this
neighborhood into an acceptable low-poverty census tract.
If the
manager fails to fill the other 80 units with people above the poverty
level, and the entire development ends up filled with people below
poverty; it will INCREASE the poverty rate of the neighborhood even
further from 26% to 34%. (see Appendix below for details
and calculations)

Location

Census
Tract

Poverty
Level
Before
Mixed
Income

Poverty
Level
After
Ideal
Mixed
Income

Poverty
Level
After
Failed
Mixed
Income

Cedar
Terrace

7246

61%

59%

67%

Magnolia

7243

26%

28%

34%

Appendix:

Cedar Terrace
Calculations:

Cedar Terrace is in Census Tract 7246 with a population of 1,793 and
60.96% of
that population is below poverty.

The residents in the PH units and the LITC/PBV will be below the
poverty level, the residents in the LITC and MR units will be above the
poverty level. If 50% of the
units are filled with residents above poverty, it would represent a
complete success for the
mixed-income scheme.

The residents in the PH units and the LITC/PBV will be below the
poverty level, the residents in the LITC and MR units will be above the
poverty level. If 50% of the units are filled
with residents above poverty, it would represent a complete success for
the
mixed-income scheme.

If Mixed-income is
completely successful, it will actually RAISE the poverty
rate from 26% to 28%; hardly an acceptable low-poverty
neighborhood,
i.e. with less than 10% poverty!

If Mixed-Income fails, and ALL 400 new residents end up below poverty,
it will RAISE the poverty
rate even further from 26% to 34%.

Note: Because
the lowest potential poverty rate at the Magnolia
mixed-income development (50%) is higher than the existing poverty rate
in the
census tract (26%), the mixed-income
development at Magnolia will RAISE the poverty
rate in the census tract whether or not it is “successful”.